Which law applies today
Some articles on "new discount rules in Ukraine" describe a law that is not yet in force. Consumer Protection Law No. 3153-IX was adopted on 10 June 2023, but under point 1 of Section IX it enters into force one year after publication and not before the day martial law is ended or lifted. On 6 November 2026 the law's card on zakon.rada.gov.ua shows the status "Entering into force".
So discounts today are governed by the old Law No. 1023-XII in the version of 24.12.2024 (status "In force"), alongside the Law on Advertising No. 270/96-VR and the Law on Protection against Unfair Competition No. 236/96-VR. There are no other rules on the base price of a discount in the laws currently in force, and the EU rule on the "lowest price in 30 days" does not apply in Ukraine other than through the not-yet-effective Law No. 3153-IX.
What the current law requires
Three rules concern the strikethrough price directly.
Article 15 of Law No. 1023-XII, Parts 4–6. The words "discount", "reduced price" or anything similar may be used only when three conditions hold at once: they apply to products this seller sells directly; the discount runs for a defined and limited period; the price is lower than the product's usual price. For the word "sale" (rozprodazh) the conditions are similar: all goods in a certain place or a clearly defined group are being sold off, the period is limited, the prices are below the usual ones. And the key point for a product card, Part 6: after a public announcement of a discount, buyers must be shown both the price set before the discount began and the price after it began. A strikethrough price is exactly how Part 6 is met, provided the price crossed out is the one that applied before the promotion.
What a "usual price" is, Law No. 1023-XII does not define. That is not a licence to raise the price the day before: Article 19 of the same law calls it misleading when a practice induces a consumer to buy through false information about "the price or the way the price is calculated, the existence of discounts or other price advantages" (Part 2, point 4), and Part 3 separately prohibits false statements about a limited selling period (point 4), offering at a special price a product that is not available (point 10), and an invented closing-down sale (point 8).
Article 8 of the Law on Advertising, Part 4. An ad about a price reduction or a sale must state the place, the start and end dates of the discount, and the ratio of the new price to the previous selling price or the size of the discount. A discount in Article 1 of that law is "a temporary reduction of the price of goods". A "−17%" banner without dates and without the previous price breaches this rule regardless of whether the discount is honest.
Article 15-1 of Law No. 236/96-VR. Spreading misleading information, in particular incomplete, inaccurate or false statements about "price and discounts", including in advertising, is unfair competition. Under Article 21 the Antimonopoly Committee may fine up to 5% of the previous year's sales revenue. This rule is about competitors, not consumers: the complaint can come from a shop that honestly sells at 1,000 while its neighbour "discounts" from 1,200 to 999.
What changes with the new law
Article 11 of Law No. 3153-IX carries over the same conditions and adds four things that do not exist today.
- A wider list of words: "discount", "reduced price", "benefit", "low price", "promotion" (Part 7).
- A deadline for the notice: the seller communicates the usual price and the new price "no later than the start day and throughout the promotion" (Part 9).
- A definition of the usual price: "the lowest price at which the seller offered the product during the last 30 days before the announcement" of the discount, or from the first day of sale if the product has been on sale for less than 30 days (Part 10).
- A duty to state the unit price next to the selling price, in the same or a larger font (Parts 1 and 4).
The lowest price in 30 days is the rule that articles present as already in effect. It will start to apply together with the law, after martial law. But it is precisely this rule that is worth adopting as a working one now: it matches the logic of Article 19 of the current law and what Google requires for a strikethrough price.
✓ requirement exists · ≈ exists with conditions · ✗ no requirement. Sources: zakon.rada.gov.ua, Merchant Center help (sale_price, sale price annotations).
Product feed rules
Google does not check Ukrainian legislation; it has its own rules, stricter than the current law in one respect and softer in another.
- Two prices in the feed. Per the sale_price attribute help, during a sale the full price stays in price and the sale price goes in sale_price, and the sale price must be lower. Both prices must be on the product page; at checkout only the sale price. If the sale price is submitted in price, Google will never show a strikethrough price: there is nothing to show it from.
- Period. sale_price_effective_date is a start and end date separated by a slash, in ISO 8601 format. Without it the sale applies immediately; without a time zone Google assumes UTC.
- When the strikethrough price appears. Per the sale price annotations help, the discount must be greater than 5% and less than 90%, both prices must be shown on the page, and the base price must have been in effect: for free listings in Brazil, France, Germany, India, Italy, Korea, the Netherlands, Spain and the UK, 30 of the last 200 days, not necessarily consecutive; for the US, Australia, Canada and Japan there is no duration requirement. The help page has no separate rule for Ukraine, and that should be read literally: the rule is not stated, which is not the same as "does not apply". The annotation is not guaranteed even when every condition is met.
- Price on the page. The price attribute must match the price on the product page and at checkout; member-only prices may not go in price or sale_price, there is loyalty_program for those. In results Google may round the strikethrough price to a whole number.
- What is penalised. The Misrepresentation policy calls "pricing practices that create a false or misleading impression of the cost of a product" an egregious violation: the Merchant Center account "will be suspended upon detection and without prior warning".
- Markup on the page. Per Google's merchant listing help, the sale price goes in the Offer's price, and the old one in a nested UnitPriceSpecification with priceType StrikethroughPrice. If priceValidUntil holds a past date, the listing may not display.
- OpenAI feed. In the OpenAI product feed specification, sale_price must be greater than zero and strictly less than price in the same currency, otherwise the field is ignored. The specification does not schedule sale dates: the feed must be updated when the sale starts and when it ends. What of this is available to a Ukrainian shop at all is in the article on products in AI assistant answers.
Conditional example: 1,200 → 999
A conditional product sold at UAH 1,000 from 1 September. On 26 November the price was raised to 1,200; on 27 November it was set to 999 with a "−17%" badge. Checking against each source.
| Source | What it sees | Conclusion |
|---|---|---|
| Law No. 1023-XII, Art. 15 Part 4 | 999 is below the pre-promotion price of 1,000, the period is limited | Formally the word "discount" is allowed, but the discount is 0.1%, not 17% |
| Law No. 1023-XII, Art. 19 Part 2 point 4 | "−17%" is counted from 1,200, which no buyer paid on any day | False information about the size of the discount: a misleading practice |
| Law on Advertising, Art. 8 Part 4 | The banner has no dates and no ratio to the "previous selling price" | The ad does not meet the requirements; the previous selling price is 1,000, not 1,200 |
| Law No. 3153-IX, Art. 11 Part 10 (once in force) | The lowest price in 30 days is 1,000 | A discount from 1,200 is prohibited; an honest discount is only from 1,000 |
| Merchant Center, sale annotations | From 1,200 the discount is 16.75%, from 1,000 it is 0.1%; the base price of 1,200 was in effect for one day | Where the 30-of-200-days rule applies there will be no strikethrough price; from the real base the discount is under 5% |
| A competitor selling at 1,000 | The neighbouring card "1,200 → 999, −17%" | Grounds for a complaint to the Antimonopoly Committee under Art. 15-1 of Law No. 236/96-VR |
The honest version for the same product: base 1,000 (the lowest price in the last 30 days), sale price 849, badge "−15%", on the card "1,000 → 849, valid 27 to 30 November". Arithmetic: (1,000 − 849) ÷ 1,000 = 15.1%. That passes Article 15 of the current law, the future Article 11, the advertising requirements and Google's 5% threshold. How many extra orders such a discount must bring so as not to eat the profit is calculated in the article on the Black Friday discount.
- Is the crossed-out price one at which the product was actually sold before the promotion?Not the manufacturer's recommended price, not a competitor's price, and not a price set the day before. No → there is nothing to cross out: this is not a discount but a new price
- Is it no higher than your lowest price in the last 30 days?Today only the logic of Article 19 and the future Article 11 require this, but this is the threshold both Google and the Antimonopoly Committee will treat as honest. No → the base for the discount is the lowest price in 30 days
- Do the card and the ad carry start and end dates?Article 15 Part 4 of the current law and Article 8 Part 4 of the Law on Advertising. "While the promotion lasts" is not a date. No → without dates the word "discount" cannot be used
- Can the buyer see both prices on the page, not only in the cart?Article 15 Part 6 of the current law and Merchant Center's product page requirement. Yes → the discount can be announced; submit price and sale_price in the feed
How to present a discount honestly
| Element | How to do it | Rule |
|---|---|---|
| Base price | The lowest price at which the product was offered in the last 30 days; for a new product, the price from the first day of sale | Art. 11 Part 10 of No. 3153-IX (once in force); today, the safe reading of "usual price" in Art. 15 Part 4 of No. 1023-XII |
| Word on the badge | "Discount", "promotion", "−15%" only together with dates and the old price; otherwise simply a new price with no badge | Art. 15 Part 4 of No. 1023-XII; Art. 11 Part 7 of No. 3153-IX |
| Product card | Old price crossed out, new price beside it, "from … to …" under the price | Art. 15 Part 6 of No. 1023-XII; Merchant Center's requirement to show both prices |
| Banner, newsletter, ad | Start and end dates, where it applies (site, store), the size of the discount or the ratio of prices | Art. 8 Part 4 of No. 270/96-VR |
| Merchant Center feed | price = base price, sale_price = sale price, sale_price_effective_date = period; the sale price never in price | Help on the sale_price and sale_price_effective_date attributes |
| Product markup | price = sale price, UnitPriceSpecification with priceType StrikethroughPrice = base, priceValidUntil = end of the sale | Google's merchant listing help |
| Member prices | Not in sale_price but in loyalty_program; on the page not as a "discount for everyone" | Help on the price attribute |
| Evidence | An export of the price history from the CMS or the feed for the 30 days before the sale, kept until the sale ends plus the period of a possible inspection | No rule: the basis for answering a complaint or an enquiry |
| After the sale | Return the price to the base or keep the new one as the usual price, but without a strikethrough; a "discount" that lasts for months stops being a discount | Art. 1 of No. 270/96-VR: a discount is a temporary price reduction |
If a promotion drags on without end it makes no sense in money terms either: the buyer gets used to the "discounted" price as the usual one, and the sales-growth formula from the Black Friday article stops holding. What else a shop's page must carry under the current law is in the article on the legal minimum for an online shop.
Our position
Take the lowest price in the last 30 days as the base for a discount now, without waiting for Law No. 3153-IX. The current law does not define the usual price, but it prohibits misleading buyers about the size of a discount; the Law on Advertising requires the ratio to the previous selling price; and in the listed countries Merchant Center will not show a strikethrough price that did not hold for 30 of 200 days. The 30-day threshold satisfies all three at once, and it is the one that becomes law after martial law. Raising the price the day before and crossing it out is the quickest way to get a competitor's complaint to the Antimonopoly Committee and a Merchant Center suspension without warning.
This position does not hold for a product that has been on sale for less than 30 days: its base is the price from the first day of sale, and only that may be crossed out. Nor does it hold for a clearance of leftover stock where the price goes down for good: then the strikethrough price leaves the card as soon as the old price stops being temporarily replaced.
Checked on 6 November 2026 against the texts of Consumer Protection Law No. 1023-XII (Articles 15, 19, 23, version of 24.12.2024, status "In force"), Consumer Protection Law No. 3153-IX (Article 11, Section IX, version of 02.03.2026, status "Entering into force"), the Law on Advertising No. 270/96-VR (Articles 1, 8, 27, version of 31.07.2026), the Law on Protection against Unfair Competition No. 236/96-VR (Articles 15-1, 21, version of 16.10.2020) on zakon.rada.gov.ua, Google Merchant Center help pages (the price, sale_price and sale_price_effective_date attributes, sale price annotations, the Misrepresentation policy), Google Search Central documentation on merchant listing markup and OpenAI's product feed specification. This is an overview of the rules, not legal advice for a specific promotion.